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Reference: 3
Contaminants of concern that were not detected in this medium are not listed.Shaded chemicals exceed comparison values.
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Contaminants of concern that were not detected in this medium are not listed.Shaded chemicals exceed comparison values.
J -- Estimated Value
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Contaminants of concern that were not detected in this medium are not listed.Shaded chemicals exceed comparison values.

J -- Estimated Value, less than Contract Required Detection Limit but above Instrument Detection Limit
ND -- Not Detected, with Detection Limit
NR -- Not Analyzed for, or not reported
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Contaminants of concern that were not detected in this medium are not listedShaded chemicals exceed comparison values.
ND -- Not Detected (with detection limit)
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

The MDPH released a draft of this Public Health Assessment for public comment on March 29,
1995. The public comment period was open until April 28, 1995. MDPH received comments
from the Environmental Manager for PCA (Reference 10) and from the MDNR site manager.
Those comments, with MDPH's responses, are repeated below. Page and paragraph references
are to the Initial Release of the Assessment.

Comments from the Environmental Manager for the Packaging Corporation of America:

Comment: We note that the six conclusions are matched by six recommendation that pertain to
the same respective subject matter, and therefore we will comment on these six items in order:

We disagree with conclusion Number 1 that the PCA site poses an "indeterminate" public
health hazard at this time and that samples of "actual surface material" should be collected and analyzed for contaminants of concern. We believe there is no public health risk and there is no need for further sampling and testing.

The ATSDR conclusion seems to be based on (a) the belief that surface samples were taken from
just below the surface instead of "actual surface material" and (b) the test results showed elevated
levels of some chemicals of concern in lagoon #1, and to a lesser extent in lagoons #2 and #3.

The surface samples were "actual surface material". The Remedial Investigation report states on
page 45 that "Surficial soil samples were collected with trowels after organic litter (grass, leaves
and roots) were removed by shovel and gloved hand." Thus surface samples were taken from the
true surface soil, with only the natural organic material removed because this would have
affected the analysis of the soil for organic chemicals. Therefore, there is no need for additional
samples and tests to characterize the surface soil.

The Baseline Risk Assessment (BRA) concluded that the level of chemicals that were present in
the surface sampled did not pose a risk to human health. Both Trespasser and Hunter scenarios
were evaluated and no Hazard Index (HI) exceeded 0.04. The EPA agreed with this conclusion,
stating in the Declaration of the Record of Decision (ROD): "EPA has determined that
conditions at the site pose no current or potential unacceptable risk to human health or to the
environment."

Moreover, the ongoing "Landfill Closure" of lagoons #1, 2, and 3 has reduced risks even more.
Lagoons #2 and 3 are being eliminated according to the "Preliminary Closure Plan for PCA
Landfill" that had been approved by both the EPA and the Michigan Department of Natural
Resources (DNR). The cellulose fiber sludge is being removed from lagoon #2 and in several
years it will be revegetated and restored to its original condition. Lagoon #3, the landfill lagoon,
will be capped with an impervious membrane and covered with 3 ft. of a clean soil vegetative
layer. About 25% of it is already capped.

In lagoon #1, all of the "soap skimmings" residue referred to on page 5 have already been
removed.

While this work is going on, access to lagoons #2 and #3 is controlled by the fence and gates mentioned in the ATSDR report.

Lagoons #4 through 8 are not a concern because, as the ATSDR report says on page 10, "The RI
contractors reported that residues from the wastes were not detected in lagoons 4, 5, 6, 7, and 8."

Response:

The description of the "surficial soil" samples collected during the RI has been
changed to agree with the description in the RI report. The description, however,
leaves open the question of how much organic material was removed. The
reference to roots raises the possibility that soil as well as loose litter may have
been removed in the process of collection. The information on the removal of
"soap skimmings" in Lagoon #1 has been added to the assessment.

We agree with recommendation #2 that it is a good idea to have restrictions on the area above
the groundwater plume to deter the installation of new wells, even though, as the ATSDR report
notes, this is unlikely to occur. However, we believe that there already are sufficient safeguards
in place. Let us bring to your attention a number of restrictions that already exist that prevent
water well development:

--

The Michigan Department of Public Health has forbidden the drilling of any new
wells in any area above the plume.

--

PCA owns most of the land above the plume and we have no objection to placing a
deed restriction on it to complement the Department of Health's proscription.

--

There already are deed restrictions on the property owned by the Village of Eastlake
and on the former Stronach Township property (which PCA has recently acquired),
that limit the use of this property to park and recreational.

--

Martin Marietta has place a deed restriction on their property that prohibits the drilling
of water wells as a result of negotiations with PCA.

Response:

The MDPH has no authority to forbid drilling of wells. The assessment has been
revised to include the information on the deed restrictions in place.

We agree with recommendation #3 that groundwater should continued to be monitored to
detect any movement of contaminants from the plume to private or municipal wells. As you
know, such monitoring is included in the EPA ROD.

In September, 1994, PCA submitted a "Work Plan for Groundwater and Surface Water
Monitoring" to the EPA and it was approved on October 17, 1994. It calls for annual sampling
of 6 residential or municipal wells, and 15 [monitoring] wells in the plume or between the plume and private and municipal wells, for the parameters listed in the ROD. The first sampling will take place in June, 1995, and it will continue indefinitely -- perhaps for 60 years or more.

Response:

Thank you for the information.

We disagree with recommendation #4 that additional hydrogeological studies should be made
to establish the structure of the geological formations underneath Manistee Lake and the extent
of the groundwater plume, to determine whether any private or municipal wells might be reached
by the contamination. We believe the geological formation and the extent of the plume have
been well established as described in the RI report. The EPA agreed in their response to
comment #6 on page 17 of the Responsiveness Summary of the ROD, saying, "The Agency
believes that enough information has been gathered to make an appropriate decision about
groundwater at the site which would be protective of human health and the environment."

We certainly share your desire to insure the safety of private and municipal wells, but we believe this is being accomplished by the comprehensive groundwater monitoring program described in item #3.

Additional facts further attest to the security of private and municipal wells.

--

The groundwater modeling that was done for the RI report shows that the plume reached
its maximum extent some time ago. Approximately ninety percent of the contaminant
mass has already vented into Manistee Lake and the plume will only decrease in size and
concentration over the next 60 years.

--

Both modeling and other data from the RI indicate that Manistee Lake is an effective
barrier to prevent contaminants from migrating to the west side of the Lake, and any
private or municipal wells on the west side will not be impacted. Aquifer testing and
modeling show that wells on the west side of Manistee Lake would have been impacted
many years ago if the Lake were not an effective barrier.

--

This is supported by test data on monitoring well #106 that has been taken since 1978.
This well is on the south edge of the plume where it is the closest to private residences. It
shows that the plume is retreating and not spreading.

SUMMARY OF ARSENIC AND COLOR CONCENTRATIONS IN MONITORING WELL
#106

Date

Arsenic
(ppb)

Color
(APHA units)

October 20, 1978

1,300

October 25, 1979

700

January 14, 1980

14

550

September 7, 1983

< 10

November 11, 1983

7.7

150

October 7, 1987

ND (10.J)

32

November 15, 1990

5.B

55

Thus, arsenic has declined from 14 ppb in 1980 to 5 in 1990, and color declined from 1,300
APHA units in 1978 to 55 in 1990. This indicates that the edge of the plume is retreating.

We expect the monitoring program will continue to show a gradually diminishing plume.

Response:

The plume is apparently diminishing because it is being washed into Manistee Lake
and the source has been eliminated. There are other possible routes for the dispersal
of the contaminant plume, and we do not agree that the available data is sufficient to
eliminate them from consideration.

We agree with the last sentence on the item #5 conclusion which states that: "There are many
other potential sources for the contamination of the lake besides the PCA site and the PCA
plant." That is one of the principal problems we have with the 1992 MDNR-contracted survey of
Manistee Lake. We are enclosing a copy of our July 30, 1993 comments that we sent to the EPA
on the draft DNR report.

Conclusion #5 recommends additional sampling of sediments and surface water in Manistee
Lake. We believe there is value in some continued monitoring of Lake conditions and we well
be conducting continued lake water testing as described in the "Work Plan for Groundwater and
Surface Water Monitoring". Lake water tests, together with bioaccumulation factors will track
effects on fish. However, if recommendation #5 means that PCA should carry on the
DNR-contractor study, we believe that this is not appropriate for the reasons stated in our June 30, 1993 comments.

Response:

The specific actions in response to Public Health Assessment recommendations
for environmental actions such as monitoring are left to the environmental
agencies to determine.

We agree with recommendation #6 that the existing MDPH advisory on consumption of fish
from Manistee Lake is sufficiently protective of human health.

Response:

Thank you for your support.

Additional minor corrections or explanations:

a. On page 2, 4th paragraph, wastewater flowed through lagoons #1 through #7 in numerical
order, but lagoon #8 was an alternate destination to lagoons #4-5-6-7 for wastewater pumped out
of lagoon #3.

Response:

The assessment has been revised to include this information.

b. On page 2, last paragraph, lagoon #2 was not pumped out in the early 1970s because it was full
of cellulose fiber sludge, not liquor that would seep into the ground.

Response:

The assessment has been revised to include this information.

c. On page 3, first paragraph, approximately one-third of lagoon #3 was capped in 1994, not
mid-August, 1993.

Response:

The assessment has been revised to include this information. The original
statement was based on observations made during the MDPH visit to the site on
August 10, 1993.

d. On page 3, first paragraph, lagoon #2 now contains cellulose fiber sludge with a little
rainwater, not the "black liquor" that was originally l agooned.

Response:

The assessment has been revised to include this information.

e. On page 8, last paragraph, the 1 lb. of PCB in 1988 was a leak from a transformer into a moat
that surrounded it. It was properly cleaned up and disposed of in accordance with all applicable
regulations. No PCB got onto the ground at the Filer Mill. This also applies to page 9, second
paragraph.

Response:

The assessment has been revised to include this information.

Comments from the Michigan Department of Natural Resources site manager:

Comment:

Page 16, Potential Exposure Pathways, Surface Water:

The last sentence states that dilution of groundwater as it discharges to surface water
will likely reduce the concentrations of contaminants to below levels of concern. In
our estimation, the data available to date is insufficient to be able to reach strong
conclusions regarding the human health risks posed by groundwater discharging to
surface water. We do know that the groundwater discharge poses significant
ecological risks, as evidenced by the high toxicity of groundwater to Ceriodaphnia
dubia, and by the abnormal distribution and numbers of pollution tolerant benthic
organisms present in the area of plume discharge. It remains to be determined to
what degree these ecological impacts signify human health impacts. Several data
gaps remain: volatiles and semivolatiles in groundwater had very high detection
limits; no surface water measurements have been made; very few of the tentatively
identified compounds in the groundwater have been positively identified; the cause
of the extreme groundwater toxicity is unknown; and no fish from Manistee Lake
have been sampled to look for bioconcentration of site indicator compounds. These
data gaps may be addressed by the site monitoring studies required in the U.S.
Environmental Protection Agency's (EPA) Record of Decision.

Response:

The text has been revised to reflect these uncertainties.

Comment:

Page 22, Recommendations, number 6:

The assessment states that the current MDPH advisory on consumption of fish from
Manistee Lake is sufficiently protective of human health. We recommend awaiting
the results of the post-ROD monitoring studies before making a final assessment of
the risks posed by consumption of fish from the lake. In our meeting ... you
expressed similar sentiments regarding the need for additional data. If your agency
has specific recommendations regarding additional data necessary to move from an
indeterminate to a more specific overall health assessment, please provide these
suggestions to the EPA or us for possible inclusion in the monitoring plan for this
site.

Response:

After internal review of the assessment and discussions with the MDNR, the text of
the recommendation has been changed to provide for evaluation of new data on fish
from the lake and reconsideration of the advisory.

Pica behavior is an abnormal consumption of non-food materials, such as soil, most often
seen in children under 5 years of age.

The estimates were computed by multiplying the national age- and sex-specific cancer
incidence rates compiled by the SEER Program by the number of people in each age group
living in the zip code area according to U.S. Census data and estimates. These products are then
summed to give the total cancer rate estimate (28).